PURPOSE OF THIS NOTICE
THE DATA CONTROLLER
As a consequence of the use of the Website, personal information concerning identified or identifiable people might be collected and processed by the data controller. The personal data controller is the company Translink Strempel & Co. Srl,, with its registered office in Milan, Via Nirone 2, that independently decides the terms and purposes of the data processing. In order to allow the users to access and use the Website and/or the service requested through the Website, personal data may be also processed by individuals appointed by Translink Strempel & Co. Srl, (hereinafter referred to as “Translink srl”) as “Data Processors”.
TYPES OF DATA PROCESSED
The contents of the Website are intended for information only and are sometimes interactive (e.g. newsletter subscription). While navigating the Website, information on the user might be acquired, including:
- Navigation data
Information systems and software procedures used to operate the Website, during the normal course of operation, acquire some personal data whose transmission is implicit in the communication protocols of the Internet.
This category of data includes IP addresses, browser type, operating system, domain name and website addresses from which the site has been accessed, information on the pages entered or exited by the users within the site, access time, navigation length on each page, clickstream analysis and other parameters regarding the operating system and the user IT environment.
These technical information data are collected and used by the data controller in an aggregate and non-identifying form and may be used for the purposes of ascertaining responsibility in the event of hypothetical IT crimes jeopardising website security.
- Data provided voluntarily by the use
This includes personal information freely provided by the Website users to register and/or access a restricted area, to request information on a specific product or service and/or write to an e-mail address.
PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The processing of data, based on the principles of lawfulness, correctness, transparency, limitation of purposes and conservation, minimization of data, accuracy, integrity and confidentiality, is carried out for the sole purpose of allowing users to know and deepen the information services accessible through the site.
The legal basis for the processing of personal data for the purposes referred to in the preceding point is the provision of a service or the response to a request for which consent is not required pursuant to the GDPR.
The provision of personal data for the purposes illustrated is optional and failure to provide it will consequently make it impossible for the Website owner to process the requests of the interested parties.
DATA PROCESSING PROCEDURES
Data shall be mainly processed using electronic procedures and media. Personal data shall be processed by the data controller only for the provision of the service requested. The processing of personal data shall have a duration equal to the minimum period of time necessary, as set out in recital 39 of the regulation, i.e. until the termination of the existing contractual relations between the data subject and the data controller, without prejudice to a further period of storage that may be required by law as provided for in recital 65 of the Regulation, as well as in other cases provided therein.
The data will not be transferred outside the European Union.
REDIRECTING TO EXTERNAL SITES
Translink srl has implemented so-called social plugins within its website. The social plugins are special tools that allow embedding social network features directly in the Website (e.g. Facebook ‘Like’ feature). All social plugins of the Website are marked with the relevant proprietary logo of the social network platform.
LINKS TO THIRD PARTY WEBSITES
Through the Website users can connect to other third-party websites by using specific links.In this regard, it should be noted that Translink srl must not be held responsible for any processing of personal data by third-party websites and/or any management of the authentication credentials provided by third-parties.
DATA SUBJECT’S RIGHTS
In accordance with article 15 of the Regulation, the data subject is entitled to access his/her personal data, to ask for their amendment and updating in case they are incomplete or incorrect, to request their deletion if collected in breach of law or regulation and to object to their processing on legitimate grounds.
- Right to rectification: shall mean the right to obtain the correction, in compliance with article 16 of the Regulation, of any inaccurate personal data, taking into account the purposes of the data processing. Furthermore, the data subject shall have the right to obtain the completion of incomplete personal data, even by submitting a supplementary statement.
- Right to erasure (the so-called Right to be forgotten): shall mean the right to obtain deletion of personal data without undue delay, in compliance with article 17, paragraph 1 of the Regulation. Furthermore, the data controller shall be required to cancel the personal data of the data subject, on the grounds of even one or more of the following reasons: a) personal data are no longer necessary in relation to the purposes for which they have been collected or otherwise processed; b) the data subject has withdrawn his/her consent to the processing of his/her personal data and there is no legal basis for their processing; c) the data subject objected to the data processing in compliance with article 21, paragraph 1 or 2 of the Regulation and there in no other prevailing legal ground for the processing of personal data; d) personal data have been unlawfully processed; e) it is required to delete personal data to comply with a legal obligation set out by the regulation or a provision of national law. In some instances, as provided for in article 17, paragraph 3 of the Regulation, the data controller is entitled not to delete the personal data of the data subject when such processing is required to exercise, for example, the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest, for purposes of archiving in the public interest, of historical and scientific research or for statistical purposes, to establish, exercise or defend a right in a legal claim pending before a court. - The right to the restriction of personal data processing: shall mean the right to obtain the restriction of the processing pursuant to article 18 of the Regulation, where one of the following conditions is met: a) the data subject has contested the accuracy of his/her personal data (the restriction will continue for the period required by the data controller to verify the accuracy of those personal data); b) the processing of personal data is unlawful and the data subject doesn’t oppose their erasure and requests the restriction of their use instead; c) the controller no longer needs them for the accomplishment of its tasks but they have to be maintained for purposes of proof, to exercise or defend a right in a legal claim pending before a court; d) the data subject has objected to the processing of personal data pursuant to article 21, paragraph 1, of the Regulation, pending the verification whether the legitimate grounds of the controller override those of the data subject. In the event of restriction of processing, personal data shall, with the exception of storage, only be processed with the data subject's consent or for purposes of proof, to exercise or defend a right in a legal claim pending before a court, or for the protection of the rights of another natural or legal person or for reasons of substantial public interest. - Right to personal data portability: shall mean the right to request at any time and obtain, in compliance with article 20, paragraph 1 of the Regulation, all personal data processed by the data controller and/or by joint data controllers in a structured, readable and commonly used format and to have them transmitted to another controller without any hindrance. In this case, the data subject concerned shall provide full identification details of the new data controller to whom he/she intends to transfer his/her personal data with his/her express written consent. - Right to object to data processing: shall mean the right, pursuant to article 21, paragraph 2, of the Regulation and to recital 70, to object at any time to the processing of his/her personal data when they are processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing. - Right to lodge a complaint with a Supervisory Authority: shall mean the right to lodge a complaint with the Personal Data Protection Supervisor, without prejudice to any available administrative or judicial remedy, where the personal data processing carried out by the data controller and/or the joint data controllers, is considered in breach of the Regulation and/or the applicable provisions of law.
EXERCISE OF DATA SUBJECT’S RIGHTS
In order to exercise the above-mentioned rights, please contact the data controller and/or the joint data controllers as follows:
Translink Strempel & Co. srl
Via Nirone 2 20123 Milano, Italia
Telefono. +41 41 510 8851
Copyright © Translink Strempel & Co. Srl – All right reserved.